High Court of Gujarat

SANJAY CHHATRASINH BARIYAversusSTATE OF GUJARAT

Disposal: 47-DISPOSAL IN ANY OTHER MODE FH
Bench: ILESH VORAR T VACHHANI

Holding

The death of the accused abates the pending criminal appeal, leading to the disposal of the confirmation case.

Summary

The sole accused, Sanjay Chhatrasinh Bariya, died by suicide while in jail. The State of Gujarat had filed a criminal appeal (No. 623 of 2023) challenging his conviction, and a criminal confirmation case (No. 11 of 2022) was pending. The High Court observed that the death of the accused extinguishes the criminal liability and renders the pending appeal moot. Consequently, the court held that the conviction appeal stands abated. In view of this, the confirmation case was also disposed of.

Issues considered

The effect of the accused's death on a pending criminal appeal and confirmation proceedings

Subjects

death of accusedabated appealcriminal confirmation casesuicide in custodypending criminal proceedings

Judgment

           R/CC/11/2022                                                   ORDER DATED: 02/03/2026




                IN THE HIGH COURT OF GUJARAT AT AHMEDABAD

                 R/CRIMINAL CONFIRMATION CASE NO. 11 of 2022
                                     With
                       R/CRIMINAL APPEAL NO. 623 of 2023
 ==========================================================
                                    STATE OF GUJARAT
                                          Versus
                                SANJAY CHHATRASINH BARIYA
 ==========================================================
 Appearance:
 MR RONAK RAVAL, APP for the Appellant(s) No. 1
 RULE SERVED for the Respondent(s) No. 1
 MR PRATIK BAROT, ADVOCATE for the Appellant in CRA No.623 of 2023
 ==========================================================

    CORAM:HONOURABLE MR. JUSTICE ILESH J. VORA
          and
          HONOURABLE MR. JUSTICE R. T. VACHHANI

                                           Date : 02/03/2026

                          ORAL ORDER
   (PER : HONOURABLE MR. JUSTICE ILESH J. VORA)


           It is reported that, the sole accused – Sanjay
 Chhatrasinh Bariya has committed suicide in jail. In such
 circumstances,                  the conviction appeal being Criminal
 Appeal No.623 of 2023 stands abated.

           In that view of the matter, Criminal Con)rmation
 Case No.11 of 2022 stands disposed of accordingly.


                                                                                   (ILESH J. VORA,J)




                                                                                (R. T. VACHHANI, J)
 TAUSIF SAIYED



Original copy of this order has been signed by the Hon'ble Judges.
Digitally signed by: TAUSIFAHMED SAIYED(HC01401), PRIVATE SECRETARY, at High Court of Gujarat on 02/03/2026 15:05:38




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